Approach to Tax

(UK publication requirements)

1. Introduction

Ensuring compliance with all legal and regulatory requirements is one of the objectives of the ALTANA Group. This is reflected in the Code of Conduct as well as in the ALTANA identity. To achieve this objective ALTANA implemented a Compliance Management System (CMS). Tax is part of the CMS and is actively managed by ALTANA’s tax function.

In order to identify tax chances and risks and to comply with tax requirements of the ALTANA Group the tasks and responsibilities connected with tax matters have been defined. These definitions are stated in a group tax policy which is valid for all ALTANA Group companies. The group tax policy also defines a tax strategy.

The central principles of ALTANA’s tax strategy can be defined as follows:

Compliance with tax legislation is compulsory. Tax compliance needs to be maintained at any time. In particular, all tax returns and tax information as well as tax payments need to be filed or made completely, accurately and on time.

The ALTANA Group endeavors to establish a good relationship to the tax authorities (“fair partnership”).

Rooms for interpretation within the tax legislation can be interpreted in favor of ALTANA. The ALTANA Group pursues active tax planning genuinely following business needs. Aggressive tax planning measures are not part of this.

Tax fraud-relevant actions are strictly prohibited.

2. Management of tax risks

ALTANA wants its tax affairs to be compliant with tax legislation. In order to achieve this the group has set up the following instruments:

In addition to these concrete measures the ALTANA management team understands the importance of tax compliance and how it is achieved. There is a constant dialogue between the management team, ALTANA’s tax function and the employees occupied with tax matters regarding the way ALTANA manages its tax risks.

Compliance Management System (CMS), including a Compliance Committee. Tax is part of the CMS as well as the Compliance Committee

Group tax policy which defines the tax strategy of the group as well as the roles and responsibilities in tax matters

Several policies for tax sub-processes which define the roles and responsibilities for these processes

Investment in tax trainings for employees occupied with tax matters

Relationships to external tax advisors in all regions ALTANA is doing business in

3. Attitude to tax planning

As a part of ALTANA’s value-driven business approach the group undertakes selected tax planning measures. In this respect, advice from external advisors is sought on a transactional basis.

We do not make use of tax planning which does not genuinely support our business activities. Aggressive or high-risk tax planning measures are not accepted for the whole group. Furthermore, we seek to minimize the risk of dispute with the tax authorities by being open and transparent about our tax affairs.

4. Attitude to tax risks

Given the scale of our business and volume of tax obligations, risks will inevitably arise from time to time in relation to the interpretation of tax law or other arrangements. ALTANA proactively seeks to identify, evaluate, manage and monitor these risks in order to ensure they remain in line with the group’s general zero tolerance policy with regard to compliance issues.

Where there is significant uncertainty or complexity in relation to a tax risk, external advice will be sought.

5. Cooperation with tax authorities

ALTANA engages with the tax authorities with honesty, integrity, respect and fairness and in a spirit of cooperative compliance. We want to establish a fair partnership with all tax authorities we are dealing with.

We employ the services of professional tax advisers to act as our agents, and in many cases they liaise with the tax authorities on our behalf. ALTANA sees this as a way to ensure we get the most of our relationship with the tax authorities, thus reducing our tax risk.

(The Group regards the publication of this document as fulfilling its duty under paragraph 16(2) Schedule 19 Finance Act 2016 for the period to 31 December 2019)